Recently, the Belgian Minister of Finance confirmed in Parliamentary Question No. 53-107, 222 that the Belgian thin capitalization rules apply to permanent establishments of non-resident companies.
Under the Belgian thin capitalization rules a 5:1 debt/equity ratio applies if the creditor (resident or non-resident) is:
| - | exempt or taxed at a reduced rate in respect of the interest paid on the debt; or | |
| - | …